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Legal Document

Privacy Policy

Last updated: 11 August 2026

1. Overview

The NeuroElite System Limited ("NeuroElite", "we", "us") operates a neurodevelopmental screening and specialist coaching platform for students aged 9–19 across Nigeria. We recognise that the information you share with us — about your child's learning, health, and education — is deeply personal. This Privacy Policy explains, in plain language, what we collect, why, how long we keep it, and the rights you have over it.

2. Data Controller

The data controller responsible for your personal data is:

The NeuroElite System Limited
RC: 9625738
Email: privacy@neuroelitesystem.com

3. Information We Collect

Account data: your name, email address, family WhatsApp number, and authentication credentials.

Child profile data: child's name, age, grade level, school, learning differences screening responses, and any notes you provide.

Screening & coaching data: assessment responses, generated risk profiles, coaching reports, session records, and milestone notes.

Payment data: transaction references and status processed by Paystack. We do not store full card numbers or banking credentials.

Communications: messages exchanged through the encrypted platform message threads (used for all clinician–client communication).

Usage data: device, browser, and interaction data collected automatically when you use the platform.

4. How We Use Your Information

  • To deliver the 68-question screening, generate risk profiles, and provide coaching services.
  • To maintain your private family dashboard and progress history.
  • To process and verify payments through Paystack.
  • To route communications between you and our clinicians through encrypted threads — never sharing personal contact details.
  • To send service notifications (payment confirmation, report publication, weekly nudges) via WhatsApp, email, and in-app channels.
  • To improve our screening instrument, content, and platform security.
  • To comply with legal and regulatory obligations under Nigerian law.

5. Lawful Basis for Processing

Under the Nigeria Data Protection Act 2023 and the NDPR 2021, we process your data on the following lawful bases:

  • Consent: given when you create an account and begin a screening.
  • Contract: to deliver paid screening and coaching services you have requested.
  • Legal obligation: to retain records and respond to lawful requests.
  • Legitimate interest: platform security, fraud prevention, and service improvement carried out in ways that do not override your rights.

6. Children's Data

Our services concern students aged 9–19. We do not process a child's data without the verifiable consent of a parent or legal guardian who holds the family account. Parents may review, correct, or request deletion of their child's data at any time. Screening results are not released until an administrator authorises release to the family account.

7. Payment Data

Card payments are processed by Paystack on our behalf. Paystack is PCI-DSS compliant and acts as the payment processor; we receive only transaction references and status. We do not store full card numbers, CVV, or PINs on our servers.

8. Sharing & Disclosure

We share your data only in the following limited circumstances:

  • With our clinicians and coaching specialists, strictly to deliver your services, via the platform.
  • With Paystack to process payments.
  • With examination bodies where you explicitly request us to support an accommodation application.
  • Where required by law, court order, or to protect the safety of a child.

We never sell personal data. We do not share clinician personal contact details; all communication is platform-routed.

9. Data Security

We apply layered technical and organisational controls: encrypted data storage in transit and at rest, row-level access controls isolating each family's records, administrator-only audit logging, and segregated access for clinical staff. Personal data is not displayed alongside clinician contact details, and internal messaging is end-to-end within the platform.

10. Retention

Screening records and coaching reports are retained for the duration of your active engagement plus seven years for clinical record-keeping purposes. Payment records are retained per financial regulations. You may request earlier deletion of your family's data subject to legal retention obligations.

11. Cookies & Local Storage

We use essential cookies and local storage to keep you logged in, remember your referral code, and preserve screening progress. We do not use your data for cross-site behavioural advertising. Analytics data is aggregated and anonymised.

12. Your Rights

Under the NDPA 2023 you have the right to:

  • Access the personal data we hold about you and your child.
  • Request correction of inaccurate data.
  • Request deletion ("right to be forgotten") subject to legal retention.
  • Withdraw consent at any time, without affecting processing already carried out.
  • Lodge a complaint with the Nigeria Data Protection Commission.

To exercise any right, email privacy@neuroelitesystem.com.

13. International Data Transfers

Our infrastructure may process data through cloud providers with infrastructure outside Nigeria. Where this occurs, we rely on appropriate safeguards and ensure protections consistent with the NDPA 2023 apply to your data throughout.

14. Changes to This Policy

We may update this policy as our services evolve. Material changes will be announced in-app and by email, and the "Last updated" date above will reflect the revision.

15. Contact

Questions about this policy or your data should be directed to privacy@neuroelitesystem.com.

Protected under the Nigeria Data Protection Act 2023